Trinity Skills for Life (“we” or “us”) is committed to data protection and data privacy. With the General Data Protection Regulation (GDPR) becoming enforceable from 25 May 2018, we have undertaken a GDPR readiness programme to review our entire business, the way we handle data and the way in which we use it to provide our services and manage business operations.
We hold personal data on all our employees/volunteers to meet legal obligations and to perform vital internal functions. This notice details the personal data we may retain, process and share with third parties relating to your employment and vital business operations. We are committed to ensuring that your information is secure, accurate and relevant. To prevent unauthorised access or disclosure, we have suitable physical, electronic, and managerial procedures to safeguard and secure personal data we hold.
We have issued this notice to describe how we handle personal information that we hold about our staff/volunteers and job/volunteer applicants (collectively referred to as “you”). For the purposes of this notice, the term “employee” includes contracted staff, variable hours staff, bank staff, work experience students, sessional staff and volunteers.
We respect the privacy rights of individuals and are committed to handling personal information responsibly and in accordance with applicable law. This notice sets out the personal data that we collect and process about you, the purposes of the processing and the rights that you have in connection with it.
If you are in any doubt regarding this notice, please contact Mike West.
Types of personal data we collect
During your employment/volunteering with us, or when making an application for employment/volunteering, we may process personal data about you and your dependents, beneficiaries and other individuals whose personal data has been provided to us.
The types of personal information we may process include, but are not limited to:
Purposes for processing personal data
If you are applying for a role with us then we collect and use this personal data for recruitment purposes – in particular, to determine your suitability for a specific role. This includes assessing your skills, qualifications and verifying your information, carrying out reference checks or background checks (where necessary) and to generally manage the hiring process and communicate with you about it.
If you are accepted for a role with us, the data collected during the recruitment process will form part of your ongoing employee/volunteer record.
For more information, please see recruitment privacy notice on our staff/volunteer application forms
We collect and process personal data relating to our employees to meet our obligations under the employment contract and to comply with our legal obligations. We take the security of your data seriously and are committed to being transparent about how we collect and use that data and to meeting our data protection obligations.
Once you become an employee, we collect and use this personal information for managing our employment or working relationship with you – for example, your employment records and contract information (so we can manage our employment relationship with you), your bank account and salary details (so we can pay you), and details of your spouse and dependents (for emergency contact).
We have policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed without authorisation and only accessed or used for specific legal purposes.
You have some obligations under your employment contract to provide the organisation with data. You may also have to provide the organisation with data in order to exercise your statutory rights, such as in relation to statutory leave entitlements. Failing to provide this data may mean that you are unable to exercise your statutory rights.
We process our employees’ personal information through our own internal systems and we ensure that all appropriate security controls are in place to protect personal information.
Legitimate business purposes
We may also collect and use personal information when it is necessary for other legitimate purposes, such as to help us conduct our business more effectively and efficiently – for example, for general IT security management, accounting purposes or financial planning. We may also process your personal information to investigate violations of law or breaches of our own internal policies.
EPX in conjunction with our IT department (Mike West) will record and monitor usage of all our IT equipment, use activity, voice traffic, email and internet usage as deemed necessary. The IT department will observe the strictest confidentiality when undertaking these activities and determine the actions that may need to be taken in any particular case.
We may also use your personal data where we consider it necessary for complying with laws and regulations, including collecting and disclosing employee personal information as required by law (e.g. for tax, health and safety, anti-discrimination laws), under judicial authorisation, or to exercise or defend our legal rights.
Legal basis for processing personal data
Our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the way we collect it. We will normally collect personal data from you only where we need it to perform a contract with you (i.e. to manage the employer/employee relationship), where we have your freely given consent to do so, or where the processing is in our legitimate interests and only where this interest is not overridden by your own interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
Any processing based on consent will be made clear to you at the time of collection or use – consent can be withdrawn at any time by contacting Mike West.
Who we share your personal data with
We take care to allow access to personal data only to those who require such access to perform their tasks and duties, and to third parties who have a legitimate purpose for accessing it. Whenever we permit a third party to access personal information, we will implement appropriate measures to ensure the data is used in a manner consistent with this notice and that the security and confidentiality of the data is maintained.
Transfers to third-party service providers
In addition, we make certain personal data available to third parties who provide services to us. We do so on a “need to know basis” and in accordance with applicable data protection and data privacy laws.
For example, some personal data will be available to our employee benefit plans service providers and third-party companies who provide us with employment law advice, health and safety support, payroll support services, expenses, tax and travel management services.
Transfers to other third parties
We may also disclose personal data to third parties on other lawful grounds, including:
Personal data will be stored in accordance with applicable laws and kept for as long as needed to carry out the purposes described in this notice or as otherwise required by law. Generally, this means your personal information will be retained until the end or your employment, employment application, or work relationship with us plus a reasonable period of time thereafter to respond to employment or work-related inquiries or to deal with any legal matters (e.g. judicial or disciplinary actions), document the proper termination of your employment or work relationship (e.g. to tax authorities), or to provide you with ongoing pensions or other benefits.
For more information, please see our Data Protection and Data Retention Policy, which outlines our current document retention schedule.
You may exercise the rights available to you under data protection law as follows:
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. You can read more about these rights at:
To exercise any of these rights, please contact Mike West
Issues and complaints
We try to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
This notice was drafted with clarity in mind. It does not provide exhaustive detail of all aspects of our collection and use of personal information. However, we are happy to provide any additional information or explanation needed.
If you want to make a complaint about the way we have processed your personal information, you can contact the Information Commissioner’s Office in their capacity as the statutory body which oversees data protection law – www.ico.org.uk/concerns.
Updates to this notice
This notice may be updated periodically to reflect any necessary changes in our privacy practices. In such cases, we will inform you via staff meetings or staff briefing notes. We encourage you to check this notice periodically to be aware of the most recent version.
Please address any questions or requests relating to this notice to Mike West.
Annex A – Third-party processors
Key third-party processors
The following are our key third-party processors who will, during your employment, process your personal data.
We work in conjunction with Citation in relation to all aspects of employment law, Citation may hold records on our employees which may include
We also work in conjunction with Citation in relation to all aspects of Health and Safety management. Citation may hold records on our employees which may include
We work in conjunction with Howards to process monthly staff salaries. Howards hold records of
Standard Life Pension
Standard Life provide employees with a work based pension who may hold records of
Newell Palmer Financial Consultants
We work in conjunction with Newell Palmer in relation to financial management such as work based employee pension. Newell Palmer may hold records of